(EU) 2023/1542 · Annex XIII(1)(e)
Recycled content in batteries: why you do not owe this yet
This is the field vendors most often sell you too early. Annex XIII does list it among publicly accessible information, but Article 8(1) ties the documentation to an entirely different date — and that date is years away.
What Article 8(1) actually says
Documentation on the share of cobalt, lithium or nickel recovered from battery manufacturing waste or post-consumer waste, and on the share of lead recovered from waste, is required from 18 August 2028 or 24 months after the delegated act enters into force, whichever is the latest. For LMT batteries the first subparagraph applies only from 18 August 2033. Industrial batteries with exclusively external storage are excluded from the first subparagraph.
The figure is per year and per plant
The regulation requires the share for each battery model per year and per manufacturing plant. This is not a one-off statement you file away — it is an annual obligation your supplier must report afresh each year. That is why the contract should be written now, even though the evidence is not yet needed.
Why we still raise it today
Because supplier contracts run for years. If you sign today without a clause on annual reporting of recycled content, you will open that negotiation in 2028 from a much weaker position.
Where it goes wrong
- Paying to prepare this data in a 2027-deadline package when the obligation starts in 2028 or 2033.
- Assuming it is a one-off declaration — it is an annual, per-plant figure.
- Confusing recycled content with recyclability. These are different concepts.
Frequently asked
Do I need recycled content data for the passport on 18 February 2027?
No. Documentation under Article 8(1) is required from 18 August 2028 or 24 months after the delegated act, whichever is the latest. For LMT batteries, only from 18 August 2033.
Which metals are covered?
Cobalt, lithium and nickel present in active materials, and lead present in the battery. The share is stated for each model per year and per manufacturing plant.
Does it apply to batteries with external storage?
The first subparagraph of Article 8(1) excludes industrial batteries with exclusively external storage.
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